U.S. Policy on Small/Light Arms Exports

Lora Lumpe, Federation of American ScientistsPrepared for American Academy of Arts and Sciences Conference on Controlling Small Arms11-12 December 1997, Washington, DC

This paper lays out the variety of channels through which small and light arms exit the United
States today. It discusses what is publicly knowable about exports through each of these channels
(that is, the level of governmental transparency surrounding such transfers) and about end-use
monitoring provisions in place to guard against misuse or diversion of U.S.-source weapons. The
paper concludes by making recommendations that could constructively reform U.S. policy and
reinforce the Clinton administration's recent initiatives to curb illegal arms trafficking.

A Focus on the Illicit Firearm Trade

In his keynote speech before the 50th UN General Assembly, President Clinton focused on the global humanitarian and security threats posed by terrorism, organized crime and drug trafficking. He
stated, "No one is immune, not the people of Latin America or Southeast Asia, where drug
traffickers wielding imported weapons have murdered judges, journalists, police officers and
innocent passersby." Citing the facility with which such criminals obtain the weapons needed for
their operations, President Clinton urged states to work with the United States "to shut down the
grey markets that outfit terrorists and criminals with firearms."

This speech marked a turning point in U.S. policy on small arms transfers. Since 1995,
efforts have evolved rapidly and on several fronts, most notably, as evidenced by President
Clinton's remarks, in the area of seeking to curb the illicit traffic in such arms. In 1996, the
administration prompted a change in U.S. law, closing a loophole which previously exempted
U.S. citizens brokering arms deals in other countries from U.S. laws and regulations. The
administration deepened its commitment to the issue in May 1997 and agreed to Mexican-backed
"fast track" negotiations through the Organization of American States on a convention against
illicit manufacture and trafficking of firearms, ammunition and related materials. That treaty was
signed by the United States and 27 other western hemisphere governments on 14 November
1997. And last June, the "group of eight" industrialized countries (G-7 plus Russia) highlighted
the threats posed by transnational crime and terrorism. The group reiterated its support for
measures to curb illicit gun-running and agreed to consider the development of an international
agreement to combat such traffic at its gathering in Birmingham, U.K. in May 1998.

The U.S. administration has also played a constructive role in relevant efforts over the past
two years at the United Nations, in the preparation of the Panel of Governmental Experts' Report
on Small Arms(1) and in development of the International Study on Firearm Regulations prepared
by the Crime Prevention and Criminal Justice Division of the Economic and Social Council(2). Both
of these studies focus significantly on the illegal traffic in arms, as well.

At the same time it is pursuing these laudable initiatives, however, the U.S. government
sells, gives or licenses for export hundreds of thousands of guns annually and vast quantities of
ammunition. Many U.S.-source small and light arms enter into illegal circulation. In 1993, foreign
governments reported 6,238 unlawfully acquired U.S.-origin firearms to the Bureau of Alcohol,
Tobacco and Firearms. Over half--3,376--were discovered in Mexico.(3) According to President
Clinton's statement at the signing of the OAS convention on illicit arms trafficking, in November
1997, the BATF received approximately 30,000 requests in 1996 from OAS member states to
trace weapons used in crimes. For the most part, these weapons are legally sold, either
domestically or abroad, and later re-transferred to another party in contravention of U.S. law.

The Channels of Supply

There are five principle means by which small arms and light weapons are exported abroad from
the United States: government-negotiated sales (called foreign military sales, or FMS); free or
low-cost transfers of surplus Pentagon arms; sales negotiated directly by the arms manufacturer or
a middleman (direct commercial sales, or DCS); covert government-run supply operations; and
illegal export of weapons. The legal arms supply channels are described in some detail below, with
an attempt made to quantify the magnitude of small/light arms transfers through each in recent
years, a description of the level of transparency surrounding each, and the prevalence of end-user
checks in place to safeguard against diversion or misuse. Some general observations are made
about illegal arms exports from the United States and covert government arms supply operations.

Three principal laws and two sets of implementing regulations govern small and light arms
exports from the United States. The Arms Export Control Act is the primary law establishing
procedures on sales of military equipment and related services. This law stipulates the purposes
for which weapons may be transferred (self-defense, regional or collective defense, and internal
security) and establishes a process by which the executive branch must give Congress advance
notice of major sales valued at $14 million or more, whether the sale is negotiated by the
government or directly by the arms industry or a broker. The Arms Export Control Act mandates
that foreign government entities gain U.S. government approval before they re-transfer U.S.-origin arms to a third party.(4) This law also authorizes the government to engage in covert arms
supply operations.(5)

The Arms Export Control Act is implemented by the International Traffic in Arms
Regulations (ITAR), which are overseen by the Office of Defense Trade Controls, in the Bureau
of Political-Military Affairs at the State Department. The ITAR contain a listing of all categories
of equipment considered "munitions." Included in the list are all firearms except for non-military
shotguns. Manufacturers or brokers wishing to export such arms must be registered with the
Office of Defense Trade Controls, and they must obtain an individual export license from the
State Department before making any arms shipment.

The ITAR also include a list of proscribed destinations. Currently, twenty-four
governments and one insurgent group are ineligible to import any American weapons.(6) The State
Department imposed these embargoes for a variety of reasons, including U.N. Security Council-mandated arms embargoes (which are binding for all U.N. members), chronic warfare, and/or a
determination that the government is a sponsor of terrorist activity. In a few other cases,
discussed below, the administration has established a policy prohibiting or restricting transfers of
small arms and crowd control equipment to particular destinations because of human rights
concerns, or concerns about diversion of weapons.

The Export Administration Act governs shipments of dual-use goods---technology with
both military and civilian applications.(7) The Bureau of Export Administration at the Commerce
Department administers this law through the Export Administration Regulations (EAR), which
contain the Commerce Control List of items regulated for export on foreign policy or national
security grounds. Included in this list, under the heading of police equipment, are non-military
shotguns, shotgun components, shotgun shells, stunguns and shock batons. Companies wishing to
export such items must first obtain a license from the Commerce Department for all entities
except those in NATO member countries, Australia, New Zealand or Japan. Governments deemed
by the State Department to be "state sponsors of terrorism" are prohibited from receiving items
controlled for export by the Commerce Department, but some other restrictions placed on State
Department-licensed arms exports do not apply to those overseen by the Commerce Department.

The Foreign Assistance Act directs the provision of economic and military aid to foreign
governments and militaries. This act provides the authority for the President and the Department
of Defense to give away stocks of surplus American arms. It includes language barring military
aid or arms sales to any country that shows a "gross and consistent" pattern of human rights
abuse. The Foreign Assistance Act also contains certain proscriptions on the supply of equipment
to foreign police forces, although many of the restrictions have been eroded by U.S. counter-narcotics programs over the past several years.

These three laws are amended yearly by Congress, usually through the annual foreign aid
and defense authorization and appropriation acts, which set the levels of assistance and weapons
procurement for the upcoming fiscal year.(8) The implementing regulations are updated often
through notices in the Federal Register, the daily bulletin of the executive branch.

Government-Negotiated Foreign Military Sales

Through the Foreign Military Sales (FMS) program, the U.S. government (represented by the
Defense Department) negotiates weapons sales directly with foreign militaries. In addition to the
weapons, the Pentagon usually contracts to deliver the goods, provide training in the operation
and maintenance of the weapons, supply spare parts, and give performance assurances. FMS may
cover sales of new equipment (procured by the Pentagon from U.S. weapons manufacturers),
coproduction of weapons overseas, or sales from surplus Pentagon stocks.

An FMS deal is usually initiated with a request for weapons transmitted from the U.S.
embassy in the customer country to the "implementing agency"---the Army or the Defense
Logistics Agency in the case of small/light arms. Copies of the request are sent to several relevant
government agencies, including the State Department's Bureau of Politico-Military Affairs, the
Defense Security Assistance Agency (DSAA) in the Office of the Secretary of Defense, the Arms
Control and Disarmament Agency and the Unified Command responsible for the region where the
customer country is located. If no objections are raised, the implementing agency, in conjunction
with the DSAA, begins to prepare the contract for the arms package. By law, the administration
must notify Congress 15-30 days before offering a sales contract to a foreign customer, if the
proposed sale is valued at $14 million or more.(9)

Congress has recently been notified of several major light weapons sales:

---In the same month, the Department of Defense informed Congress of its planned sale of
130 M2 .50 caliber machine guns to Saudi Arabia, as part of a much larger ($1.075 billion)
sale of light armored vehicles.

---In June 1997, the Pentagon announced the proposed sale of 1,065 Stinger anti-aircraft
missiles and 213 gripstock missile launchers to Taiwan as part of a larger $307 million
deal.

Due to a law passed in 1996, notifications to Congress of proposed FMS are now printed in the
Federal Register, the daily bulletin of the executive branch. The notices are usually published
within two weeks of transmittal to Congress, and the Federal Register is available via the internet,
meaning that information on some government negotiated small/light arms sales is widely
available to the public prior to finalization of the sales contract.(10) The vast majority of light
weapons deals, however, fall below the $14 million notification threshold and receive little or no
Congressional or public scrutiny.

Until recently, the only source of information on past shipments of government-brokered
small arms sales was through submission of a request under the Freedom of Information Act
(FOIA), a law directing that the executive branch release all requested information to the public
that is not exempt from disclosure (national security and foreign policy reasons are grounds for
exemption). Detailed information obtained from the Defense Department in 1994 showed that
between 1980-93, the Pentagon transferred nearly 50,000 pistols, over 170,000 rifles and
shotguns, nearly 1,000 submachine guns, and more than 12,000 grenade launchers to 49 countries
through FMS (see appendix 1).(11) Given the magnitude of the recent light arms sale to Thailand,
mentioned above, these figures are surprisingly low, but still consequential. Among the data
included were the following transfers:

In response to a subsequent FOIA request for the same information for the period 1994-96, the
Department of Defense provided information on which small/light weapons were exported to
which countries, and the date they were shipped, but declined to include the quantity delivered.
Thus, while it is impossible to discern the magnitude of the exports, it was shown that during
1994-96:(12)

--Egypt took several deliveries of M2 .50 caliber machine guns;

--Lebanon and Oman each took one delivery of M2 .50 caliber machine guns;

--Bolivia, Colombia and Tunisia each took delivery of M249 5.56mm machine guns; and

--Egypt, Estonia, Israel, Latvia and Lithuania all took delivery of M16A1 assault rifles.

A new requirement established in U.S. law in 1996 now causes the Pentagon to report to
Congress (and the public) annually on all FMS deliveries, by country, and by weapon system,
during the preceding year. The first iteration of the report, known as the "section 655 report" after
the section of the Foreign Assistance Act which mandates it, was released in September 1997. It
lists out nearly $12.7 billion of weapons exported in toto through FMS in fiscal year 1996.
Among other small arms deliveries, it lists 30,450 rifles and 169 machine guns to Taiwan and 292
machine guns and 39 rifles to Thailand.(13) Detailed information of the sort contained in the section
655 report was provided to Congress throughout the 1970s, but the Reagan administration
repealed the legislation mandating it in 1981. Reinstatement of this report greatly facilitates
Congressional and public oversight of U.S. small arms sales policies.

According to a recent report on end-use monitoring of FMS shipments, "whether a minor
item, which is readily available commercially [e.g., small arms] or a high technology weapon
system, each defense item transfer must be preceded by formal agreement with appropriate end-use and retransfer restrictions."(14) The report goes on to note that the Defense Department's
"physical security requirements for transfers to foreign governments of arms, ammunition and
explosives are similar to those required by U.S. military forces." Security Assistance Offices,
located in U.S. embassies around the world, are charged with in-country management of weapons
sales programs, including oversight of end use. However, there is no indication that any routine or
surprise end-use inspections are undertaken to assure physical control and non-transfer.

Theft of weapons from U.S. military depots is a significant source of black-market arms
within and from the United States, and it is reasonable to assume that foreign control of arms sold
through the FMS program are equally, if not more, vulnerable to theft and/or diversion.
Allegations long persisted, for example, that the Thai government---whether through negligence
or official policy---was diverting U.S.-supplied (and other) light arms to Khmer Rouge
combatants in neighboring Cambodia. In December 1993, one of several Khmer Rouge arms
depots on Thai soil was inadvertently exposed to the press, and U.S.-designed weapons were
photographed in the arsenal.(15) The practice apparently continues on an ad hoc basis today,
although pared down significantly in the past few years. Meanwhile, some of the U.S. M16 assault
rifles and other light weapons that flowed into Cambodia, have been re-exported back through
Thailand to rebels fighting the military government in Burma.(16)

Surplus Weapons Grants from the Government

In addition to sales of newly-manufactured weapons, the Pentagon gives away or sells at deep
discount the vast oversupply of small/light weapons that it has in its post cold-war inventory.
Most of this surplus is dispensed through the Excess Defense Articles (EDA) program. The
Foreign Assistance Act defines EDA as weapons or other items owned by the U.S. government,
which were not procured in anticipation of military assistance or sales requirements. Originally
only the southern-tier members of NATO were cleared to receive EDA, but following the 1991
Gulf war, many Middle Eastern and North African states were added; anti-narcotics aid provisions
expanded EDA eligibility to include South American and Caribbean countries; and the
"Partnership for Peace" program made most Central and Eastern European governments eligible
for free surplus arms.

Around 1995, largescale grants and sales of small/light arms began occurring (see
appendix 2). In the past few years (1995-early 1998), over 300,000 rifles, pistols, machine guns
and grenade launchers have been offered up, including:

Excess equipment is generally transferred in furtherance of U.S. foreign policy goals, such as
narcotics control, military alliance or encouraging participation in multilateral peacekeeping
operations. In addition, there is a budgetary inducement for the military services to unload the
surplus weapons, rather than bear the expense of storing or destroying them.

Most provisions of law that apply to sales of new weapons also apply to transfers of
surplus arms. In fact, EDA are the most transparent of all U.S. arms exports. In 1993, at the
urging of the arms industry, the Pentagon created a computer bulletin board on excess weapons
sales and grants.(17) When the Pentagon notifies the foreign aid committees of Congress of
upcoming EDA weapons transfers (required 30 days prior to shipment, no matter the value of the
equipment, whether grant or for sale), the information is posted on the bulletin board. In addition,
the section 655 report itemizes all grant EDA offered to each country during the preceding fiscal
year.

That report also lists surplus weapons provided during the preceding year under special
Presidential authority to "draw down" U.S. military equipment to meet emergency needs. The
Foreign Assistance Act provides permission for the President to transfer on a grant basis up to
$150 million of military articles from U.S. stocks annually.(18) The executive branch has used this
provision increasingly in recent years, particularly in support of counter-narcotics efforts. In
addition, Jordan and Bosnia have taken delivery of large quantities of surplus light arms under this
emergency authority. The law requires the President to notify Congress of any planned
drawdowns of equipment, and also to notify Congress upon completion of delivery.

Section 623 of the Foreign Assistance Act requires the Department of Defense to
supervise end-use of weapons provided under grant aid programs. This function is delegated to
Security Assistance Offices located in overseas embassies. According to an August 1997 report
on end-use monitoring, "As part of their normal duties, SAOs are responsible for observing and
reporting on utilization by the host country of defense articles and defense services, including
training." Again, there was no indication in the report, however, that this observation or reporting
is routinely, or even occasionally, occurring in most recipient countries.(19) The State Department,
however, does appear to conduct some end-use checks of small arms provided under the special
drawdown authority in support of drug control operations. During 1995, the U.S. embassy in
Bogota inspected M16A1 rifles, M60 machine guns, M9 pistols, shotguns, M79 grenade
launchers, 60mm mortars, and ammunition that had been shipped to Colombian forces.(20)

In addition to concerns about the repressive nature of some of the governments taking
delivery of weapons through this program (discussed below), the precedent of exporting---rather
than destroying---surplus small arms is potentially dangerous. Several other countries have (or
had) large surplus arms holdings. The Federal Republic of Germany, for example, inherited the
entire military of the German Democratic Republic; many former Soviet republics inherited
arsenals in excess of their ability or desire to field soldiers. Liberal transfers of excess arms by the
United States, for economic or diplomatic gain, may be used as justification by these and other
states for similar actions, contributing to a further proliferation of guns.

Some past U.S. transfers of surplus light weapons have come back to haunt American
policymakers. Beginning in the 1950s, the Department of Defense gave or sold nearly 2.5 million
World War 2-era military pistols, rifles and carbines to some 40 governments around the world
(see appendix 3). South Korea, Vietnam, Turkey, Pakistan, Cambodia and the Philippines were
the largest recipients of the weapons---M1911 .45 caliber pistols, M1 carbines and M1 Garand
rifles. Now the pro-gun lobby in the United States is seeking to force the executive branch
(through an act of Congress) to allow American citizens to import these old model, but still quite
lethal weapons---referred to as "curios and relics" by the National Rifle Association. The
Departments of Defense, State, Justice and Treasury, along with the White House, are firmly
opposed to allowing these weapons into civilian circulation.

Industry Direct Arms Sales

Despite the large quantities of small/light arms sold through FMS and given away through surplus
programs, the vast majority of such weapons are exported from America through direct
commercial sales (DCS), negotiated between U.S. companies or brokers and foreign buyers. The
foreign customer may be a government entity (e.g., interior ministry, justice ministry, ministry of
defense, or national police), a corporation or person using the weapons for private security, or a
gun vendor. DCS must be approved by the State Department's Office of Defense Trade Controls
or the Commerce Department's Bureau of Export Administration, depending on the equipment.
State Department-licensed sales are subject to the same Congressional notification procedure as
are FMS (that is, for sales over $14 million). Commerce Department-licensed sales are not subject
to any prior Congressional scrutiny.

In general, when the customer is a government entity, the choice of whether to use the
government-to-government channel or to deal directly with the arms manufacturer or broker is up
to the purchaser. Most public and policy attention focuses on government-negotiated FMS, since
that program is much more visible and has accounted for the majority of U.S. arms exports in
dollar terms over the years. Arms export licenses approved by the State Department's Office of
Munitions Control (later renamed the Office of Defense Trade Controls) totaled some $2-3 billion
annually during most of the cold war, with much of this believed to comprise small/light arms. By
the mid-1980s, however, license approval averaged $10 billion annually, and since the 1990-91
Gulf war, licenses have shot up to an average of more than $25 billion a year. State Department
officials are quick to point out that DCS license approvals do not represent final sales; they
estimate that about a quarter to half of the licenses approved will result in actual exports. Still,
this represents a dramatic increase in the value of industry-negotiated arms sales.

The growing popularity of direct sales is due to the fact that the commercial route is
quicker, sometimes cheaper and entails less oversight than do government-negotiated sales. In
addition, both the Commerce and State Departments are much less transparent about the deals
they are licensing than the Pentagon is about sales it is negotiating.(21) Many foreign customers
have viewed this secrecy with favor.

State Department-licensed Small Arms Exports

The section 655 report now makes it possible to tally the vast quantities of small arms, light
weaponry and ammunition that the State Department is clearing for export. The report for 1996
lists out in great specificity some $470 million of small arms and ammunition which the State
Department authorized manufacturers to export directly to foreign countries.(22) It is possible to
quantify the value of licenses granted for ammunition and ammunition manufacturing equipment,
carbines, grenades/grenade launchers, machine guns, submachine guns, pistols, M16 rifles, other
rifles, etc. to each recipient country. It is important to note, though, that this information only
concerns licenses that have been approved by the State Department, rather than actual delivery of
items. These licenses are valid for four years.

Because the State Department previously refused to release any information about small
arms sales it has licensed,(23) it is not possible to determine relative changes in the volume of
exports or licenses over time. However, the State Department's Office of Defense Trade Controls
reported in mid-1994 that it had experienced a recent noticeable increase in the number of
applications for firearm and ammunition exports.(24) Data obtained by Congressional investigators
showed that during 1989-93 the State Department granted 1,600 export licenses for over $100
million of pistols, revolvers and rifles to eight Latin American countries (see below).(25)

value of licenses

no. of licenses

no. of end-use checks

Argentina

$47,747,115

686

7

Brazil

$3,957,533

343

2

Colombia

$643,785

39

0

Costa Rica

$556,274

117

0

El Salvador

$891,916

61

3

Guatemala

$6,766,983

141

3

Mexico

$34,362,973

108

3

Peru

$11,704,189

137

3

Total

$106,630,768

1,632

21

Around this same time, according to a State Department bulletin, foreign governments
requested that the United States be more careful in licensing small arms and ammunition for
export. Concerned about the quantity of firearms entering their countries, and the possibility for
diversion to terrorists, drug-traffickers and criminals, governments requested that the U.S.
government demand more extensive documentation for license applications. As a result, the State
Department modified the regulations governing firearms exports in several ways. First, a firm and
specific purchase order must be submitted with a license application. Second, a "nontransfer and
use" certificate is required for export applications for 50 or more handguns or rifles, or 100,000
or more rounds of ammunition. Third, an import authorization issued by the importing
government is now required, as well.(26)

In 1990, the State Department initiated a global end-use monitoring program known as
"Blue Lantern." The program, required by an act of Congress,(27) is administered by overseas
diplomatic posts, under the direction of the Office of Defense Trade Controls. Embassy personnel
verify directly with local authorities and foreign firms or persons the bona fides of proposed
transactions. They also perform some random spot checks. Some 3,000 cases have been initiated
since the program began (on an estimated 50,000 licenses granted annually). Investigations are
triggered when someone included in the State Department's watch list applies for an export
license, or when other key flags indicating high risk transactions are raised. These include:
requested equipment that does not match the known requirements or inventory of the foreign end
user (including requests for spare parts); insufficient information about parties to the transaction;
or involvement of a foreign broker in a third country. But information revealed through a
Congressional hearing showed that the State Department conducted only 21 end-use checks on
1,600 license approvals granted for gun exports to Latin American countries during 1989-93 (see
preceding page).

Nevertheless, according to an August 1997 report, the State Department believes that the
Blue Lantern program has effectively disrupted several "grey arms market transactions" and had
an important deterrent effect in dissuading bogus imports.(28) In 1996, thirty-one cases referred to
Blue Lantern resulted in export license denial; nearly half of these cases were in Latin America,
and most of the remainder were in Europe.(29) As a result of one recent investigation, the U.S.
government instituted a ban on firearms exports for commercial purposes to Paraguay, and sales
to the government and police are now subject to a high degree of scrutiny.(30) According to a U.S.
embassy official in Asuncion, "The diversion of arms and munitions from Paraguay to neighboring
countries (chiefly Brazil) is becoming a major regional issue. The Blue Lantern program provides
us with a mechanism for measuring and controlling U.S. commercial exports to Paraguay."(31) The
program also reportedly heightened British officials' awareness of the need to monitor more
closely commercial U.S. small arms exports to the U.K. and uncovered two cases of fraudulent
orders in Bolivia---one concerning sniper rifles allegedly for the government and the other
involving phony import permits issued by the ministry of defense.(32)

A recent State Department Inspector General report agrees that the program is becoming
more aggressive and effective, but acknowledges that it is still implemented unevenly at different
embassies. In particular, the report cites communication problems between the embassies and the
Washington, frivolous investigation requests, and sloppy or non-existent record keeping on
investigations. The Inspector General took several recommendations from embassy personnel, one
which would waive Blue Lantern checks for certain U.S. munitions list items, including hand guns
or "other sporting armaments."(33)

Maintaining control over licensed manufacture in foreign countries of U.S.-design
small/light arms is another area of concern. In 1988 the General Accounting Office disclosed that
South Korean industry had violated the terms of a license by Colt for the manufacture of M16A1
assault rifles, producing them in excess of the permitted quantity and exporting the rifles without
U.S. government approval. The State Department classified the names of the third-country
recipients, but a member of Congress disclosed in a hearing that they were "hostile." The
Pentagon maintained that the exported rifle, known as the K-2, is a "Koreanized" version of the
M16, but with enough modification that it could be considered "indigenous" and, therefore,
exempt from U.S. government export controls. Other countries which have produced M16A1
assault rifles under license are Canada, the Philippines, Singapore and Taiwan. Chartered
Industries of Singapore now produces an M16 clone which it exports widely.

Commerce Department-licensed Exports of Shotguns

The Commerce Department is also secretive about what precisely it is licensing for export
to which particular entities in foreign countries, but it is possible to glean some data. In response
to a request under the Freedom of Information Act about shotgun exports licensed during 1991-93, the Department released country-specific data on the quantity and dollar value of licenses
approved for the commodity category that includes shotguns (as well as shotgun components,
shotgun shells, stun guns and shock batons). According to this information, over $100 million in
exports of these items were approved during the three-year period (see appendix 4 for value by
country). At an average price of $200 per shotgun, this translates into roughly 500,000 guns
approved for export during this three-year period.

Although it is impossible to know with certainty, since this information is not released, the
bulk of these licenses were probably for 18 or 20" Mossberg, Maverick and/or Winchester 12-gauge shotguns, shells, rifle scopes and sights. Smith & Wesson, EI Dupont de Nemour, Bausch
and Lomb Inc., Olin Corporation, Valor Corporation of Florida, and U.S. Repeating Arms are
some of the principal U.S. manufacturers and exporters of these weapons and components.

No doubt boosted by active assistance from the Commerce Department, in the form of
letters to overseas embassy staff instructing them to promote gun sales, shotgun exports have
apparently increased in recent years, as well. In fiscal year 1995, the Commerce Department
approved 1,301 licenses, valued at over $75 million---nearly as much as it had licensed during
1991-93.(34) The following year, Commerce signed-off on over $67 million in shotgun exports,
while rejecting just under 50 applications (valued at nearly $3 million) for shipment to entities in
Vietnam, Nigeria, Indonesia and other countries.(35) Taken together, these figures represent
foreign sales of approximately 700,000 12-gauge shotguns in 1995-96. These figures actually
under-represent total sales, since U.S. manufacturers and middlemen do not need a license to
export crime control items to destinations in NATO member countries, Australia, Japan and New
Zealand.

The guns are exported both to private dealers for commercial resale, and to ministries of
justice, interior or defense for use in the importing country. Section 6(n) of the Export
Administration Act imposes controls on the export of police equipment principally because of
human rights concerns. According to a recent Commerce Department report, "Applications for
licenses will generally be considered favorably on a case-by-case basis, unless there is evidence
that the government of the importing country may have violated internationally recognized human
rights and that the judicious use of export controls would be helpful in deterring the development
of a consistent pattern of violations or in distancing the United States from such violations."(36) The
document goes on to say that the State Department's annual Country Reports on Human Rights
Practices will be consulted in making licensing decisions. Information on which states received
high levels of gun export licenses from the Commerce Department in 1995-96 is not publicly
available, but appendix 4 lists several recipient countries during the 1991-93 time period with
severe human rights violations, high levels of armed violence, or a history of diversion. Among
the countries of greatest concern on these grounds are Guatemala, Israel, Pakistan, Paraguay,
Peru, Thailand, Saudi Arabia, and Venezuela. The Commerce Department's Bureau of
Export Administration performs no dedicated end-use monitoring on exports of shotguns,
components, and ammunition. BXA's Office of Enforcement Support is responsible for
preventing and investigating export control violations. It has over 140 staff, half of whom are
special agents, located in Washington headquarters and eight field offices around the country.
These agents are empowered to make arrests, carry firearms, execute search warrants and seize
goods about to be illegally exported. The enforcement office also examines export license
applications to assess risk of diversion, but the focus is on major strategic weapons---especially
technologies used in nuclear, chemical or biological weapons or missiles. In 1996, the Commerce
Department, through the Office of Enforcement Support and Foreign Commercial Service staff in
overseas embassies, conducted 427 pre-license checks and 234 post-shipment verifications (on
tens of thousands of export licenses granted annually). Two cases closed during that year dealt
with illegal exports of light weapons.(37)

Covert Government Arms Supply

Clandestine U.S. government operations are another way in which small/light arms are exported
from or by America. The National Security Act of 1947 authorizes covert political and military
operations, including secret arms supply. The president must first make a "finding" that the
operation is vital to U.S. national security. Section 505 of the act requires the Central Intelligence
Agency, or other government agencies engaging in such activities, to notify the Congressional
committees responsible for oversight of U.S. intelligence community activities of any arms supply
operation undertaken valued at $1 million or more.

During the 1970s, and particularly during the Reagan administration, covert arms supply
operations run by the Central Intelligence Agency (or the National Security Council) were a major
source of small/light arms to insurgent groups around the world. Some of this weaponry was
manufactured in America; some, in an effort to hide U.S. support of the operation, was not.

Because these programs are classified, little is known with any precision about the frequency,
magnitude and specifics of covert arms supply. Information is sketchy even for the most public of
these operations, which armed, trained and financed guerrillas fighting communist-backed state
forces in Nicaragua, Angola and Afghanistan.

The classified operation to arm various mujahideen factions fighting in Afghanistan to
liberate the country from Soviet invaders began in 1979. Before it ended in 1991, the CIA had
shipped via Pakistan an estimated 400,000 AK-47 assault rifles; an undisclosed quantity of Stinger
portable anti-aircraft missile launchers and missiles; vast quantities of Italian-made anti-personnel
mines; 60,000 archaic rifles, 8,000 light machine guns and over 100,000,000 rounds of
ammunition from Turkey; 40-50 Oerlikon Swiss-designed anti-aircraft guns; mortars from Egypt;
Blowpipe surface-to-air missiles from Britain; and 100,000 rifles from India.(38)

Covert U.S. aid to insurgents in Angola began in 1974 and continued until 1992. It is
estimated that during the 1970s, the CIA provided some $300 million in aid, most of it through
neighboring Zaire, and much of it in the form of light weaponry. Former CIA operative John
Stockwell wrote that in the early phase of the operation (1970s), the CIA provided 7,771 7.62mm
rifles; 12,215 .30 cal carbines; 4,210 66mm light anti tank weapons, and 410 grenade launchers.(39)
It is not publicly known how many weapons were transferred to the National Union for the Total
Independence of Angola (UNITA) and President Mobuto in Zaire when the operation was
intensified by the Reagan administration in the mid-1980s.

The recycling of weapons transferred through the CIA or White House covert pipeline is a
major contributor to continuing violence and instability today in Central America, South Asia and
Southwest Africa. Because of the secret and un-accountable nature of these transactions, they
feed directly into the global black arms market.

It is generally believed that the use of covert military supply operations has greatly
diminished in the 1990s, and yet calls for armed destabilization of the regimes in Iran and Iraq
persist. Most recently, it has been reported that the CIA is considering plans for covert support to
Iraqi Kurdish and Shiite groups to sabotage the Iraqi economy and propel the overthrow of
President Hussein.(40) On-going covert arms supply to forces opposing the Sudanese regime is also
reported, as well.

Illegal Exports

In part, the Clinton administration's recent focus on the illicit arms traffic was spurred by the
concerns of the Mexican government about the proliferation of illegal U.S. weapons in the hands
of Mexican drug-traffickers and other criminals. According to the Bureau of Alcohol, Tobacco
and Firearms (BATF), Mexico is one of the leading recipients of illicitly exported U.S. weapons.
Guns flow from and through America to Mexico in several ways.

On 14 March of last year, when federal agents opened two crates in a "left cargo" hold at
the Otay Mesa border crossing near San Diego, they uncovered the largest illegal shipment of
arms ever intercepted in the United States en route to Mexico. The weapons---thousands of
unassembled grenade launchers and parts for M2 automatic rifles---had been sitting unclaimed for
two months. The shipment had originated in Vietnam, where America left behind large quantities
of weapons, including M2 automatic rifles.(41) Before the arms returned home, they were well-traveled, having gone from Ho Chi Minh City to Singapore to Bremerhaven, Germany, through
the Panama Canal and up to Long Beach, California, where the weapons entered the United
States in two large, sealed containers.(42) The contents were falsely represented as hand tools and
strap hangers, but U.S. Customs at Long Beach did not inspect the cargo, since the shipment was
"in-bond"---that is, the items were simply transiting the United States to another country, in this
case Mexico. In-bond cargo containers typically remain sealed as they move from ship to truck to
border. According to a Customs source, "in the normal course of business, no one would have
ever opened them. [The arms] were discovered through a fluke."(43) (The shipment was held up at
the border because the Mexican freight forwarder commissioned to get the crates to Mexico City
did not have an address for the purchaser.) The in-bond system is built on trust, and on the
Customs Department's lack of resources. Customs has fewer than 135 inspectors at the port of
Long Beach, the nation's busiest port.(44)

Nevertheless, the Customs Department has successfully thwarted a number of illegal arms
export efforts, many of them involving small arms shipments. For instance, in 1997 several
defendants were indicted for attempting to export illegally 53 AR-15 rifles from the United States
to Colombia. In another case in 1997, Customs blocked an attempt to import surface to air
missiles from Bulgaria for transhipment to Colombia. The Department also successfully
prosecuted a former Venezuelan secret service agent for the unlawful shipment of 120 firearms to
Venezuela between 1993-95.(45) Unfortunately, there is no way to know what percentage of the
illegal trade is being intercepted.

Large and relatively well-organized arms shipments like the one intercepted in San Diego
last March are thought to be unusual. A more routine way of smuggling arms across the border is
the hormiga (ant) run: repeated trips across the border with one or a few guns. A legally eligible
or "straw" purchaser buys a few weapons (often cheap .22 and .25 caliber pistols, "38 specials,"
and 9mm pistols) from gun stores in El Paso and other American border towns and hands them
over to the trafficker, who smuggles them across the border, generally either on foot or in the
trunk of a car. This process is repeated thousands of times a year, as smugglers make repeated
trips to gun stores and shows in Florida, Texas and California, in particular.(46)

Some legal constraints are now in place, but lack of investigative and regulatory resources
reduce their efficacy. The "Brady Bill" mandates a national system of background checks prior to
gun purchases. Until that system is up and running (by November 1998), a mandatory five-day
waiting period prior to purchase is in effect. And a rule recently enacted by the Clinton
administration requires purchasers to show that they have lived for at least three months in the
state where they are buying a gun. And the 1994 assault weapons ban curbs purchases by civilians
of automatic and semi-automatic weapons.

The Firearms Owners Protection Act of 1986 (sponsored by the NRA) requires that
multiple sales be reported to the BATF and local law enforcement agencies, so that they can
monitor multiple gun purchases and investigate if they suspect criminal intent. But currently only
three states---Virginia, Maryland and South Carolina---have laws that prevent people from buying
more than one gun a month. In all other states, straw purchasers can buy significant quantities of
guns and ammunition from gun dealers at one time and pass them on to smugglers for clandestine
shipment. A 1991 BATF report describes a number of such transactions, including a 1989 case in
which three Arizona residents purchased 93 assault rifles and 22 handguns for a well known
Mexican narcotics trafficker, who then smuggled them into Mexico.(47)

U.S. military depots are another likely source of supply. In 1993, the General Accounting
Office (GAO) found that small arms parts were routinely stolen from a number of U.S. military
repair shops and warehouses. The parts were then sold to gun dealers or to walk-in customers at
gun shows around the United States. GAO investigators were able to purchase military small arms
parts at 13 of 15 gun shows they visited. They were able to buy everything needed to convert a
semiautomatic AR-15 rifle into a fully automatic M16, as well as 30-round M16 magazine clips
still in their original packages.(48) Given the paucity of end-use checks performed on U.S.-supplied
arms (described above), it is reasonable to assume that theft from Mexican depots contributes to
the black market in arms, as well.

Conclusion and Recommendations

The United States continues, as during the cold war, to be a major exporter of light weaponry
around the world, and by all available evidence, legal exports of shotguns, small arms and
ammunition have been increasing in recent past years. Because other governments are not open
about their light weapons shipments, it is not possible to rank the United States' place in the
global small arms trade; however, give the sheer magnitude of U.S. licenses and sales---in 1996
the State Department approved $470 million of small arms exports, the Commerce Department
approved $75 million of shotgun exports, and the Department of Defense gave away 50,000
assault rifles and over 10,000 grenade launchers---it is reasonable to speculate that America
dominates the market (as it does the market for larger weapons systems).

In the 1990s, America's threat perceptions have shifted dramatically. No longer facing a
global nuclear confrontation with the Soviet Union and its allies, civil and regional wars (and the
chaos they spawn), drug trafficking, international terrorism, and other forms of transnational
crime are now considered among the most serious threats. The administration has identified a link
between the illegal traffic in arms and several of these threats, but it has yet to acknowledge the
link between massive legal U.S. light arms exports and the illegal traffic. Other governments
understand this connection, and they have been pressing the United States to be more restrictive
and careful in its supply. Initiatives like the recently-concluded OAS treaty, when ratified and fully
implemented, should help curb illicit gun-running, but there is more that the Clinton
administration could be doing to reinforce its stated goal of shutting down the grey market in
arms.

Embargo light arms to repressive regimes. Several of the countries currently receiving
large quantities of arms through surplus programs or buying weapons through commercial
channels are engaged in conflict or have extremely poor human rights records. Bahrain, for
instance, has received significant quantities of free machine guns, ammunition and grenade
launchers in recent years. At the same time, government forces have fired live ammunition and
tear gas into crowds of demonstrators demanding a restoration of the parliament, which the ruling
family dissolved in 1975. In addition to some measure of representative democracy, protestors are
demanding freedom of speech, the release of political prisoners, and the return of deported
dissidents. Israel, the leading beneficiary of U.S. military and economic aid, used U.S.-supplied
arms in its deadly 1996 assault in Lebanon, in which an ambulance and a U.N. refugee camp were
apparently targeted as they were thought to be shielding Hezbollah guerrillas. Under surplus grant
arms programs, Israel has received nearly 75,000 M16A1 rifles, 2,500 M204 grenade launchers,
and large quantities of ammunition. Morocco, also a major recipient of U.S. surplus small arms, is
governed by a highly repressive monarchy which has illegally occupied the Western Sahara for 20
years and long thwarted a negotiated peace process.

And, according to the State Department's 1996 human rights report, the Colombian police and
armed forces were responsible for "widespread human rights abuse" in 1995, including political
and extrajudicial killings, kidnappings and torture.(49) Colombia is a major recipient of grant surplus
arms for counter-narcotics purposes.

Small arms---and assault rifles in particular---have long been the principal symbol of state
repression, used by police, internal security forces and allied militias to crush opposition
movements, eliminate dissidents and terrorize populations. The Christmas-time massacre in
Chiapas of 45 unarmed civilians, carried out by government-affiliated paramilitary forces with
high-powered AK-47 assault rifles is one of countless examples. In addition to being immoral,
transfers of such tools to repressive governments likely encourage insurgent forces to seek
countervailing arms through the black-market---the principal source of supply open to them.

The Clinton administration has, in at least two recent cases, announced a policy of barring
sales of small arms to U.S. friends or allies on human rights grounds. In February 1994, the State
Department announced that it would deny licenses for the transfer of small or light arms and lethal
crowd control items to Indonesia. Later that same year, Congress passed law codifying this ban
until certain human rights conditions are met. The ban is still in place.

According to a July 1997 State Department report to Congress on Turkey's use of U.S.
supplied weapons, "U.S. policy is to restrict the sale of arms that clearly could be used to repress
a civilian population, such as small arms and violent crowd-control devices."(50) But the report goes
on to note that Turkey now produces the majority of its own pistols, rifles and hand-held
automatic weapons. And Turkey's paramilitary Jandarama and the Turkish National Police---the
forces most prominently cited in the commission of gross human rights abuses in Turkey---have
purchased M16 and AR-15S assault rifles and M203 grenade launchers through State
Department-licensed commercial sales. According to the State Department report, "In July 1995,
in Tunceli province, following the death of several of their comrades, members of these special
teams went on a rampage, indiscriminately firing on shops and residential buildings and attacking
individuals at random."(51) The State Department said that no resources are available generally to
monitor the end-use of U.S. supplied weapons in Turkey, to ensure that they are not being used in
the commission of gross abuses, but "mission personnel have seen some of this equipment, which
is still in service."

A comprehensive ban on small arms exports---those overseen by the Departments of
Commerce, State, Defense and intelligence agencies---should be implemented on all repressive
forces, as identified by the State Department in its annual Country Reports on Human Rights.

Provide more transparency. As evidenced by this paper, there is an increasingly high
level of transparency around U.S. small and light arms exports. And yet, compiling this
information from the various sources is time-consuming and difficult. Moreover, some key
information is still withheld from the public. In particular, the section 655 report should include
information on which State Department-licensed arms are actually shipped abroad, in addition to
listing out those items licensed for export. The State Department needs this information in a
computerized and searchable form in order to facilitate and improve end-use verification of
weapons exports it is authorizing. In addition, increased transparency would allow the non-governmental community, as well as Congressional staff, to play an important role in aiding the
administration's efforts to curb the illicit arms traffic by providing oversight through research and
questioning of discrepancies in the data. This information is also important to aid and relief
workers, who might be working in a region where a sudden influx of guns has occurred.
Transparency around such shipments could prove to be an early warning indicator of pending
violence and instability. On a more positive note, increased openness about weapons shipments
could serve as a confidence-building measure among forces within a state, or states in a region,
potentially heading off some purchases spurred on by "fear of the unknown." Finally, the U.S.
government and/or non-governmental groups could use the example of relative openness by the
U.S. government in terms of its small/light arms exports to press for similar levels of transparency
by other small arms exporters.

Controlling the domestic gun market is vital to U.S. national security. Given that drug-traffickers and terrorists have been identified as a major post-cold war threat, the United States
must do more to prevent such criminals from obtaining lethal firepower in America. The "Brady
Bill" (requiring a five-day waiting period and criminal check prior to gun sales) and the ban on
sales of assault rifles have complicated business for gun-runners. Also needed is a national law
limiting customers to one gun purchase per month. Such a measure would, according to BATF
findings, help curb the multiple-gun straw purchases that often end up on the black market.

Take the issue seriously. Finally, a policy of reflexive approval of large shipments of light
arms to security forces and private actors in friendly states around the world should give way to a
new, more restrictive norm. In short, in light of the increased security threat posed by the illicit
traffic in arms (as stated by the administration), the issue of light arms proliferation in general
should be viewed more seriously. As part of this recognition, there is perhaps a need for the
administration to press Congress for increased resources for Customs and Commerce Department
special investigations and routine inspections. In addition, rather than relegating light arms to the
back burner as is currently the case at the Commerce Department, or removing them from end-use coverage entirely, as is under consideration by the State Department, these agencies need to
undertake more frequent "end-use" inspections of small/light arms shipments to ensure that legal
transfers are not being diverted into the black market..

Note: In some cases, data in this appendix is based on the Pentagon's notifications to Congress of intended transfers, rather
than actual deliveries, since delivery data was not available for several years. When possible, we relied on actual deliveries.
This appendix is not complete; transfers of the categories of equipment covered here which were made under emergency
drawdown authority are, for the most part, not included. Sources: Defense Security Assistance Agency, House International
Relations Committee, Excess Defense Articles Bulletin Board

Appendix 3: Foreign Military Sales and Grants of World War 2-era Surplus Arms, 1950-96

Recipient

M1911 pistols

M1 Carbines

M1 Garand rifles

Totals by Recipient

Bolivia

1,213

9,033

4,034

14,280

Cambodia

16,439

31,207

23,009

70,655

Chile

1,510

266

1,181

2,957

Colombia

221

957

1,178

Costa Rica

1,026

6,000

7,026

Dominican Rep.

1,500

1,500

Ecuador

30

30

60

El Salvador

916

786

1,702

Ethiopia

2,287

2,086

4,373

Fiji

57

57

Greece

10,834

32,002

5,607

48,443

Guatemala

1,141

5,000

8,549

14,690

Honduras

1,677

5,150

1,369

8,196

Indonesia

1,429

24,418

25,847

Iran

27,914

32

27,946

Italy

100,000

100,000

Japan

1,168

1,168

Jordan

18,827

18,827

Laos

2,968

1,245

13,160

17,373

Lebanon

100

5,000

5,100

Liberia

5,087

767

3,850

9,704

Morocco

1,130

1,130

Nigeria

100

100

Pakistan

13

118,627

118,640

Panama

409

79

30

518

Paraguay

138

30,749

30,887

Peru

10

10

Philippines

27,632

15

32,705

60,352

St. Kitts

22

22

St. Lucia

22

22

St. Vincent/
Grenada

54

54

Saudi Arabia

5,000

5,000

South Korea

12,811

999,641

299,061

1,311,513

Taiwan

743

2,398

1,309

4,450

Thailand

11,041

15,066

8,854

34,961

Tunisia

92

160

6,636

6,888

Turkey

48,546

136,670

185,216

United Nations

5,000

5,000

Uruguay

1,552

7,424

7,422

16,398

Vietnam

88,925

127,891

102,641

319,457

Totals by Gun

278,370

1,245,761

957,569

2,481,700

Note: Some of the surplus gun exports listed in Appendix 2 may be duplicated here. Source: Data provided by the State
Department to the Office of Senator Frank Lautenberg, 26 September 1996

3. U.S. Department of the Treasury, Bureau of Alcohol, Tobacco and Firearms, "International Traffic in Arms
Annual Report for FY 93."

4. See section 3. This provision technically refers only to government-negotiated arms transfers, but the State
Department has interpreted it to apply to commercially-negotiated sales, as well. The law will likely be modified
soon to make this coverage explicit.

5. See section 40(h), which references covert arms supply operations authorized under title V of the
National Security Act. Section 505 of that act requires the administration to notify Congressional intelligence
oversight committees of clandestine arms exports valued at $1 million or more.

6. As of January 1998, the governments of Afghanistan, Armenia, Azerbaijan, Belarus, Burma, China, Cuba,
Cyprus, Haiti, Iran, Iraq, Liberia, Libya, Nigeria, North Korea, Rwanda, Somalia, Sudan, Syria, Tajikistan,
Vietnam, Yemen, Yugoslavia (Serbia and Montenegro), and Zaire (now called Democratic Republic of the Congo)
are unable to import munitions from the United States, as is UNITA in Angola. See the State Department's
embargo reference chart, http://www.pmdtc.org/country.html Not all of these destinations are prohibited from
importing police equipment, including shotguns, licensed by the Commerce Department.

7. Technically this law lapsed in 1994, but it continues to be implemented under emergency powers of the
President. Congress will likely rewrite and reinstate the law soon.

8. Both the Arms Export Control Act and the Foreign Assistance Act, as most recently amended, are published
annually by the Congressional foreign relations committees. The joint committee print, entitled Legislation on
Foreign Relations, is available for purchase from the Government Printing Office.

9. Fifteen days pre-notification is required for NATO allies and "major non-NATO allies," such as Israel,
Egypt, Jordan, Argentina, Australia, New Zealand, Japan and South Korea. For all other countries, Congress has
30 days to review proposed sales.

10. The Federal Register is on-line through the Government Printing Office homepage at
http://www.access.gpo.gov/su_docs/aces/aces140.html

12. Office of the Asst. Secretary of Defense, 8 November 1996. Some of the deliveries reported here were sales
or grants of Excess Defense Articles, and are reported in greater detail in Appendix 2.

13. U.S. Department of State and U.S. Department of Defense, "Foreign Military Assistance Act Report to
Congress, Fiscal Year 1996," September 1997.

14. The White House, "End-Use Monitoring of Defense
Articles, Defense Services and Related Technology,"
18 August 1997. This report is required annually by
section 40A of the Arms Export Control Act, which
Congress added in 1996 because of concerns about
inadequate end-use monitoring of government-negotiated arms exports.

20. 20U.S. Department of State, Bureau for International Narcotics Control and Law Enforcement, "End-Use
Monitoring Report," February 1997, p. 12.

21. 21The Commerce and State Departments cite section 12(c) of the Export Administration Act as blocking the
release of information on sales they are licensing, even for items long ago shipped abroad. This section of law
states that "information obtained for the purpose of consideration of, or concerning, license applications...shall be
withheld from public disclosure unless the release of such information is determined by the Secretary to be in the
national interest." The provision presumably is intended to safeguard sensitive business information about deals in
the works, but why the information would remain proprietary after the sale has been won and the commodities
have been shipped is not clear.

22. U.S. Department of State and U.S. Department of Defense, "Foreign Military Assistance Act Report to
Congress, Fiscal Year 1996," September 1997.

23. 23A request under the Freedom of Information Act in 1994 for information on small arms exports licensed by the
State Department during 1980-93 yielded nothing. The State Department claimed that section 12(c) specifically
exempted the information from disclosure.

30. A Blue Lantern check found a false order for firearms by the national police in Paraguay. The fraudulent
documents misspelled the name of the chief of police and provided an identification number which referred to a
traffic accident, rather than a purchase order. U.S. Department of State,
Congressional Presentation Document for Foreign
Operations for Fiscal Year 1999, p. 1160.

31. U.S. Department of State, Office of Audits, Memorandum Report 6-CI-023, "Review of Department of State
Export Controls and Watchlist Process," September 1996, p. 6.

44. Anne-Marie O'Connor and Jeff Leeds, "U.S. Agents Seize
Smuggled Arms," Los Angeles Times, 17 March 1997. A recent Congressional hearing focused on the
adequacy of the Customs Department's $2.1 billion budget, noted that Customs has just 167 people in its
investigative unit in Los Angeles, less than half the number in each the New York and Florida branches. Jeff
Leeds, "Customs Staffing Disparity Seen to Favor East," Washington Post, 20 October 1997.

45. U.S. Department of Justice, Export Control Enforcement Unit, "Significant Export Control Cases," 5
September 1997.

46. As of July 1997, there were 108,591 federally-licensed firearms dealers in the United States. Of these, 1,860
were in Arizona; 7,138 in California; 955 in New Mexico; and 7,922 in Texas. According to the Bureau of
Alcohol, Tobacco and Firearms, most of the U.S.-origin firearms traced to crimes in Mexico during 1994-97 came
from Houston, Tuscon, Phoenix, El Paso and Dallas.

47. U.S. Department of the Treasury, Bureau of Alcohol, Tobacco and Firearms, Firearms Division, International
Traffic in Arms, Report to Congress (1991), p. 132.

49. U.S. Department of State, "Colombia," Country Reports on Human Rights Practices for 1995.

50. According to the report, "The U.S. has not sold violent crowd-control devices to Turkey
in several years. Arms sales are reviewed on a case by case basis." U.S. Department of State, "U.S.
Military Equipment and Human Rights Violations," submitted to Congress on 1 July 1997, p. 3.